Rating (Coronavirus) and Directors Disqualification (Dissolved Companies) Bill

Written evidence submitted by Paul Sewell BSc. FRICS IRRV(Hons) MEI, Managing Director of The Machinery Users’ Association Inc. [1] (RDDB03)

Our interest is solely in respect of the Rating matters in section 1. We have no interest in the Director Disqualification issues.

1. We note that the intended legislation will duplicate the existing SI 398 of 2021 for any CCA Checks originating after 25/3/2021. The SI therefore already caps the size of any problem.

2. We understand that Local Government requires certainty of funding and limitation of future CCA appeals.

3. The only purpose of this part of the Bill appears to be to make the effect of the SI retrospective.

4. We are not generally in favour of retrospective taxation, although the concept is within the powers of Parliament.

5. The Bill is most unfair to ratepayers who arranged their affairs in a timely manner and submitted CCA Checks by 25/3/2021. In particular, it prejudices ratepayers who have refused or repaid existing grants or reliefs but who have still borne considerable Covid costs. Some of these ratepayers will have relied on getting back something from what were quite valid and very long established valuation arguments.

6. The estimate of 500,000 CCA Checks that would require resolution is grossly excessive, as duplicates have been made in most cases following the various lockdown and regulation change dates.

7. Any reductions conceded would be strictly time limited, ending when normality returns or on 31/3/2023, whichever is the sooner. Ratepayers still have the burden of proving their case and having a relevant Material Day.

8. I would ask the Committee to consider an amendment to reflect my point 6 above. If not inclined to do so on an unrestricted basis, they could give thought to; Either, imposing a cap on MCC refunds as a result of Covid reductions, perhaps in line with the figure of £2m per Company or Group in aggregate (suggested figure chosen to fit in with the 2021/22 RHL Rates billing cap). Or, limiting it to Companies/Groups who repaid or declined Covid grants or reliefs (some of whom may also refuse this as well)

Thank you for considering these thoughts.

2 July 2021

[1] a non-profit organisation (Reg. 00083398) representing the interests of members and clients on property taxation matters


Prepared 7th July 2021